Many readers ask this author "Why don't you publish Medicare payment information immediately after the Medicare Physician Fee Schedule (MPFS) Final Rule is released?" Actually, this author used to publish MPFS payment changes right after release of the Final Rule. Unfortunately, the Final Rule is not always final. For the past few decades, significant changes have often been made after the Final Rule was released and before the MPFS was implemented in January. In fact, the nearly 9% payment reductions announced in the 2022 MPFS Final Rule were softened by the passage of the "Protecting Medicare and American Farmers from Sequester Cuts Act" on December 10, 2021, which:
* Reduced the 2022 conversion factor slightly, from $34.8931 to $34.6062
* Delayed restoration of the 2% sequestration cut until April 1, 2022, when 1% of the sequestration cut will be implemented; the last percent will then be implemented on July 1, 2022
* Postponed the 4% deficit-related reduction required by the Pay-As-You-Go Act of 2010 until 2023
2022 MPFS PAYMENT CHANGES
Of course, this author immediately reviewed the revised 2022 MPFS national allowable rates for the procedures and services frequently performed by wound/ulcer management physicians/qualified health professionals (QHPs). In most instances (except for 99454 remote physiologic monitoring [RPM] device supply), the conversion factor reduction only resulted in small decreases in allowable rates (the reductions varied from a few cents to a few dollars). The good news is that the 2022 MPFS allowable rates for some important procedures and services increased. Because most of the increases were for work performed in the physician/QHP office, following is a list of procedures and services that have increased allowable rates.
* Debridement of subcutaneous tissue (11042)
* Paring or cutting of benign hyperkeratotic lesion (11055, 11056, and 11057)
* Application of epidermal autograft (15110 and 15111).
* Application of dermal autograft (15135), tissue cultured skin autograft (15150 and 15151), and skin substitute graft (15271 through 15278)
* Graft of derma-fat-fascia (15770)
* Grafting of autologous fat harvested by liposuction (15771 through 15774)
* Chemical cauterization (17250)
* Application of a paste boot (29580)
* Self-management education and training (98960 through 98962)
* Debridement of open wound devitalized tissue (97597). NOTE: Because this is the most common debridement performed after an initial surgical debridement, this increase should be welcomed by all.
* Disposable negative-pressure wound therapy (97607 and 97608). NOTE: This procedure has a sizeable increase that should make this option attractive.
* Office/outpatient visit, new patient (99202 and 99203) and established patient (99211 and 99212)
* Domiciliary or rest home visit, established patient (99334)
* Prolonged clinical staff service (99415 and 99416). NOTE: Similar to the prolonged physician/QHP outpatient/office visit service (G2212), the clinical staff must document the start and stop time.
* Online digital evaluation and management (E/M) service (99421 and 99423). NOTE: This is another terrific opportunity to provide assessment services during the COVID-19 public health emergency (PHE).
* Virtual check-in by physician/QHP (G2252). NOTE: Virtual check-in services (G2012 and G2252) are excellent opportunities for patients and providers to communicate real-time and to determine if an in-person or telehealth encounter is needed. Because these are communication technology-based services, the telehealth rules do not apply. For example, there are no geographic limitations. However, the calls cannot be related to E/M services provided within the previous 7 days or followed by an E/M service within 24 hours or the next available appointment.
* Interprofessional telephone/internet/electronic health record consultation (99447, 99448, 99449, 99451, and 99452). NOTE: This author continues to encourage those with wound/ulcer management expertise to provide this consult to physicians with less or different expertise.
* Hyperbaric oxygen therapy, full body chamber (G0277)
* Medical nutrition therapy (97803 and 97804)
* Telehealth facility fee (Q3014). NOTE: The 2022 Medicare allowable rate for this service ($27.59) was published in the 2022 MPFS Final Rule CMS-1751-F.1
In summary, all wound/ulcer management physicians/QHPs should review their location's 2022 Medicare allowable rates.2
NEW SERVICE CODES WITH MEDICARE PAYMENT
Because the American Medical Association (AMA) and the CMS continue to recognize the clinical value of remote monitoring, five new remote therapeutic monitoring (RTM) codes were created by the AMA and funded by the CMS for 2022. This allows for nonphysiologic data to be collected by psychiatrists, NPs, and physical therapists who can bill Medicare directly. Because the CMS designated these codes as "sometimes therapy" codes, physicians/QHPs may also use the codes outside a therapy plan of care.
Three of the new codes (98975 through 98977) are for RTM services ordered by a physician/QHP. Examples of RTM services are musculoskeletal system status, respiratory system status, therapy adherence, and therapy response that provides a functionally integrative representation of patient status. The RTM must be performed (1) by a medical device as defined by the FDA and (2) at least 16 days per month. NOTE: Although these new codes are analogous to RPM codes (99453, 99454, and 99457), RTM services should not be reported when RPM services are reported.
Two of the new codes (98980 and 98981) are for RTM treatment management services provided by a physician/QHP who uses the results of the monitoring to manage a patient under a specific treatment plan., including at least one interactive communication with the patient or their caregiver per month. NOTE: Code 98980 can only be reported once a month. Because these are time-based codes, physicians/QHPs should review the AMA's instructions about the time spent performing other services that should not be counted toward RTM treatment management time.
Further, because preventive services often require additional time, two new add-on codes pay for covered preventive services. The Healthcare Common Procedure Coding System code G0513 is for the first 30 minutes of prolonged preventive service(s) in the office or other outpatient setting requiring direct patient contact beyond the usual service, and the Healthcare Common Procedure Coding System code G0514 is for each additional 30 minutes of prolonged preventive service(s).
ADDITIONAL 2022 PAYMENT OPPORTUNITIES
Because the PHE is still active, all of the telehealth waivers are still effective. In addition, most of the services that CMS designated as "Category 3" services can be provided via telehealth through December 2023. The list of permanent telehealth services, the temporary services that can be performed via telehealth until the end of the PHE and those that can be performed via telehealth through December 31, 2023, and the telehealth services that can be performed audio-only can be viewed on the CMS website.3 Certain conditions must be met to perform audio-only services: (1) the service must be for established patients, (2) home is the eligible originating site, (3) the patient must have had an in-person service within the prior 6 months and a 12-month subsequent in-person visit, and (4) the telehealth provider must have the capability to provide live video but used audio-only because the patient did not have or chose not to use live video.
In the past, Medicare payment for work performed by a PA could only be made to the PA's physician employer. Effective January 1, 2022, Medicare can make payment directly to PAs who bill the program for their services. The PAs may also reassign their rights to payment for their services and may choose to incorporate as a group (comprised solely of practitioners in their specialty) and bill the Medicare program. Similar to Medicare payment to NPs, Medicare payment to PAs is 85% of the MPFS allowable rate. NOTE: PAs are still required to perform their services under physician supervision.
Registered dietitians and nutrition providers are paid at 100% (instead of 80%) of 85% of the MPFS allowable rates for their services. Because their services are considered preventive, cost sharing for coinsurance and deductible is not required.
Finally, the CMS revised the de minimis policy to determine whether services are provided "in whole or in part" by physical therapy assistants or occupational therapy assistants when a physical therapist or occupational therapist appropriately supervises them, respectively. For a detailed description and examples of this revision, this author recommends MLN Matters MM12519.4
REFERENCES